Complying with needle safety
regulations remains a challenge. The bloodborne patho-gens standard is the most
frequently cited in Occupational Safety and Health Administration (OSHA) inspections
of hospitals. Here are some frequent questions and answers about needle safety
compliance provided by the Safety Institute of Premier Inc., an alliance of
1,700 nonprofit hospitals and health systems based in Oak Brook, IL. More information
is available on the Premier web site at www.premierinc.com/safety.

If there is a safety
device available for a particular procedure, does it have to be used?

If there are safety devices
available for a particular procedure, they should be evaluated by frontline
workers and one selected for use to reduce risks. The only exception to the
use of a safety device, when available, is if the device(s) interferes with
a clinical procedure and cannot be used without compromising the procedure or
increasing the risk to the patient. In this case, the specific reason for not
selecting and using the device needs to be documented in the exposure control
plan. As part of the annual review, there should be an evaluation of any other
newer devices that might be available that might not interfere with the specific
procedure. This review, and the results of the evaluation should be documented;
that is, either the adoption of device, or an explanation of why the device
(s) interferes with a specific clinical procedure and/or increases risk to the
patient.

Can cost be a consideration
in the process of selection of a safety device and still meet the intent of
OSHA?

Cost certainly is an important
consideration as is the cost-effectiveness in choosing a safety device. However,
it cannot be the only consideration. The most important consideration, according
to OSHA, is that frontline workers are involved in choosing the device, as opposed
to the employer selecting
a device just because it is the lowest in cost. There may be opportunities for
cost-effective devices under a group purchasing contract; however, the devices
chosen by the frontline worker must be implemented whether or not they are covered
by
a group purchasing contract.

What is the definition
of "frontline worker"?

Frontline workers are those
who actually use the safety devices and could be staff nurses or charge nurses,
for example, not management staff who do not use these devices.

Are employers responsible
for providing safety devices for contract workers?

Yes, and the employer must
provide safety devices to all employees at the work site if they are at risk
of exposure to contaminated sharps, even if they are employed by another company
in a contractual arrangement. For example, contract or per diem workers in a
hospital are employees of the contracting agency; however, they still must be
provided with safety devices, personal protective apparel, and training for
compliance with all the requirements of the bloodborne pathogen standard. In
some instances, some of the requirements are managed or paid for by the contracting
agency and not the hospital, such as hepatitis B vaccination.

However, both employers
(hospital and contracting agency) are responsible for making sure that all aspects
of the OSHA standard are enforced by one of the employers, and this must be
clearly documented in the contract.

Please clarify the need
for continual (annual) evaluation of new devices. If the injury rate
has been reduced and there are no reports of employee dissatisfaction, what
is our obligation to review/consider a different device?

OSHA cannot tell an organization
exactly what it needs to do in an annual review, except the intent of the review
is to make sure that the devices being used remain appropriate, control the
hazard and reduce risks to workers. The type of review can be determined by
the employer and outlined in the exposure control plan. The intent is that you
would not choose a device and keep using it year after year despite employee
complaints and documented ongoing problems with the device. Nor does it mean
you evaluate every device on the market every year. Rather, you would conduct
an annual review of your program that would include a review of your devices.
For example, your exposure control plan could outline which factors or data
you would review/consider in your annual review. The precise type of annual
review (and what data will be reviewed and by whom) and what devices are evaluated,
if necessary, should be outlined in your plan.

In some small facilities
or departments, where sharps injuries are rare, there might not be a need for
a formal meeting, but rather the exposure control plan would outline an ongoing
assessment and review of any injuries or exposures to determine if a change
in a device or procedure is necessary.

The annual review could
be as simple as a review of data and discussion at a safety or infection control-related
meeting, with documentation in minutes. It might include documentation, for
example, of your sharps injury data and mention of any considerations in the
annual review (e.g., feedback from staff on acceptance of current device, etc.)
such as:

• If injuries are identified,
they need to be assessed to determine if the injury is from the device or perhaps
some other issue such as overfilled disposal containers that needs to be addressed.

• If no injuries have occurred
with a particular device or injury rates are reduced, it may be determined that
a review of a new device is not needed.

If there is an increase
in injuries from a specific device and all the injuries occur during activation
of the safety mechanism, it might indicate the need to evaluate a different
device.

It is important to evaluate
the nature and circumstances of sharps-related injuries that occur and not attempt
to calculate injury rates to compare safety devices that will rarely be statistically
significant. Rather, you should look at trends and nature and circumstances
of specific injuries to glean important information.

This is a performance-oriented
standard, not a "specification standard." As such, each work site needs to develop
and modify, if needed, their exposure control plan based on their work site
data. The plan will include information on how their program is managed, including
the annual review, and method for selection of devices with frontline worker
input. This plan will vary with each facility and depend on the types of risks,
review of institutional-based injury data, types of procedures performed, patient
populations, and other considerations. All device selection and evaluation will
be done with frontline worker input.

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